Hello, everyone and welcome to our Monday Minute.
Today I want to share with you a very important update on the requirements that CMS had tried to impose via transmittal on April 27, 2022. That transmittal included an update to the Home Health Medicare manuals, chapter seven, section 30, where it was going to require that Physician Assistants, Nurse Practitioners, and Clinical Nurse Specialists to specifically document their collaboration with an overseeing physician into the clinical record. The conversation that immediately ensued between the National Association for Home Care and Hospice and CMS identified that CMS was interpreting the regulation to mean that even in states where the state did not require a nurse practitioner to even work under a physician; where those states allow full reign to those nurse practitioners, they still needed to document collaboration with an overseeing physician.
The National Association along with the Association for Nurse Practitioners met with CMS to discuss what this meant in terms of their expectation in home health documentation. As a result of that meeting, and I’m sure other concerns that have been expressed, as of June 6, 2022, Transmittal 11386 has been rescinded and replaced with Transmittal 11447. Transmittal 11447 basically removed that section of the manual that they were updating regarding that additional documentation requirement.
I wanted to share this with you today, primarily because we have received many phone calls and emails about clarification regarding exactly what type of documentation would be required in the home health chart. I have been telling people that that this was being addressed with CMS, and we have seen that now come to fruition. CMS is continuing to evaluate exactly how they feel about this process. We do believe that there will be more questions about exactly what they’re expecting, versus allowing the states to carry full reign with these regulations. As of now, you are to see if your state allows Nurse Practitioners, PAs, and Certified Nurse Specialists to sign orders and certify patients in home health and if the state allows to not require any additional oversight, collaboration, documentation, etc. from an overseeing physician.
This is a fabulous example of how the National Association for Home Care and Hospice, and the state Home and Hospice Care Associations work so diligently on your behalf on a daily basis. I hope that if you are a certified agency, home health or hospice and you do not have memberships with your state or national associations that you do take immediate steps to reconcile that situation, as the work that they do daily affects us all.
Thank you to those associations for your diligent work. Thank you all for listening in today, and I hope to see you in a live conference soon.
Link to Transmittal: https://www.cms.gov/files/document/r11447bp.pdf